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CCIIO sets new deadline for transition from partnership to state-based exchange

Posted on January 3, 2013 | No Comments

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According to a guidance released today by the U.S. Department of Health and Human Services (HHS)’s Center for Consumer Information and Insurance Oversight (CCIIO), states operating State Partnerships Exchanges for plan year 2014 that intend to transition to a State-based Exchange for plan year 2015  have until November 18, 2013 to submit a Declaration Letter and a Blueprint Application to HHS.

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An updated memo released from the Congressional Research Service (CRS) outlines the number of deadlines the federal government has missed during implementation of the Affordable Care Act (ACA). The memo consists of three tables, each representing a year after ACA enactment, with a list of the statutory tasks intended to have been achieved that year and the actions taken by the administration on that task as of April 15, 2014. According to Politico, the administration still has about 22 outstanding deadlines on ACA implementation.
A new report by the Commonwealth Fund, conducted by researchers from Georgetown University's Health Policy Institute, discusses the progress state-based Exchanges (SBE) have made in designing and developing their Exchanges. The report, Implementing the Affordable Care Act: Key Design Decisions for State-Based Exchanges, found many of the SBE will likely exceed requirements placed upon them under the Affordable Care Act (ACA). For instance, several states will be reporting quality data in their individual Exchange in 2014, while others will be offering the employee-choice model in the small business health options program (SHOP) Exchange also for plan year 2014. These findings bolster the claim that states created their Exchanges in a manner that is most conducive to and reflective of the needs of their residents.
The Center for Consumer Information and Insurance Oversight (CCIIO), a division of the Centers for Medicare and Medicaid Services (CMS), recently posted new guidance concerning federally-facilitated and state-based Exchanges (Marketplaces) established under the Affordable Care Act (ACA). The guidance purports that if states do not adhere to and enforce the requisite standards for health insurance issuers in federally-facilitated Exchanges, then CMS intends to coerce enforcement through civil penalties and plan decertification. CMS does not believe that decertification will be a common occurrence. In addition, the guidance stated that qualified health plans (QHP) paired with health savings accounts (HSA) must meet the cost-sharing reduction standards that apply to low income-individuals. CCIIO published additional guidance that expands upon which activities, in both federally-facilitated and state-based Marketplaces, that qualify for grant funding under ACA Section 1311. For instance, state-based Marketplaces are not permitted to use this funding for navigator outreach and education, yet they are allowed to use Section 1311 funds for "in-person assistance programs."
The Centers for Medicare and Medicaid Services (CMS) released a draft letter to issuers regarding Federally-facilitated and State Partnership Exchanges. This guidance letter offers technical and operational guidance that will permit Qualified Health Plan (QHP) issuers to operate successfully in Federally-facilitated Exchanges and Federally-facilitated SHOPs, including State Partnership Exchanges. One specific resource addressing requirements presented in this letter is a database of essential community providers (ECPs). ECPs treat low-income individuals in medically underserved areas. Although non-exhaustive, this database is designed to provide CMS an estimate regarding the number of ECPs in a QHP's service area.
Late yesterday, U.S. Department of Health and Human Services (HHS) Secretary Kathleen Sebelius extended the deadline for states to decide whether to run their own exchange until December 14, 2012. The Republican Governors Association (RGA) sent a letter requesting the extension to Sebelius on Wednesday November 14, 2012, just two days prior to the initial deadline. This is the second time in a week that the Secretary has made extensions to key Exchange deadlines, having also recently extended the deadline to submit the state-run exchange blueprint paperwork (also December 14, 2012) and the deadline of whether a state will choose to partner with the federal government on their exchange (February 15, 2013).
U.S. Department of Health and Human Services (HHS) Secretary Kathleen Sebelius today extended the deadline for states to submit Exchange Blueprint documents, until December 14, 2012. States must still notify HHS of their intent to pursue a state-run exchange by November 16, 2012, but now have an additional month to formally submit the Blueprint. Additionally, the deadline for states to decide on whether to pursue a state-federal partnership Exchange has been extended until February 15, 2013, a full three months beyond the original November 16, 2012 deadline. This decision by HHS should allow states more time to make crucial post-election decisions as to what kind of Exchange they intend to pursue, as well as allow the Administration more time to issue key regulations.
The US Department of Health and Human Services (HHS) published guidance today on the implementation of the federally-run fallback exchange that the government will run in states that are not ready to operate a state-run exchange. In addition to the higher level operational approach, the paper also discusses how states can partner with HHS to implement selected functions in a Federally-facilitated Exchange (FFE), key policies organized by Exchange function, and how HHS will consult with a variety of stakeholders to implement an FFE. HHS also released a draft blueprint for approval of state-based or state-federal partnership exchanges. State exchanges must be certified by HHS by the beginning of 2013.
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The Affordable Care Act (ACA) establishes Affordable Insurance Exchanges, which are entities that facilitate the purchase of Qualified Health Plans (QHP) and provide for the establishment of the Small Business Health Options Program (SHOP). Previous GPS Implementation Briefs have covered these topics here and here.
On May 16, 2012, the United States Department of Health and Human Services issued a Draft Blueprint for Approval of Affordable State-based Exchanges (SBEs) and State Partnership Exchanges (SPEs). HHS also issued General Guidance on Federally Facilitated Exchanges (FFEs). Together, these two documents provide additional implementation information related to the final Exchange regulations issued by HHS on March 27, 2012, (click here for the regulations) which broadly describe the structural and operational requirements for state Exchanges, specify the Exchange approval process, and provide for FFEs in states that do not elect to operate a state Exchange. The newest guidance amplifies on the approval process for both state-based Exchanges (SBEs) and state Partnership Exchanges (SPEs) as a sub-class of FFEs but with...